Game Meat Laws January 2006

HOW WILL THEY EFFECT THE AVERAGE DEER STALKER? 

by Hugh Rose

The answer is "not much" as long as the deer stalker is already properly qualified! However, the new laws will have a much greater effect on small game dealers/processors and those estates who currently sell oven ready game or venison.

Different Levels of Dealing in Game - There is still some confusion as to what game dealing practices will be allowed in UK next year. Our national game dealing laws will remain in force so, to sell any venison or game, a Game Dealing Licence in England or a Venison Dealing License in Scotland will still be required. These licenses will be continue to be administered by local authorities on behalf of FSA.

However, next year anyone who "supplies" game (which includes just giving it away) will be required to register as a food business with the local authority. Their game larder (and perhaps even vehicles) will also have to be registered and they must keep traceability records. Registration is just what it says and the authorities will only visit if they consider the quantities involved and consequent risk justifies it.

Any hunter who is registered as a food business and game dealer with the local authority will be allowed to sell small quantities of game and game meat locally to a final consumer or a retail outlet without veterinary inspection or full HACCP. There is still official discussion going on as to whether restaurants or hotels are retail establishments. It will be up to the local Environmental Health Officers how much selling they allow before the whole operation has to be "approved" by them from a health and hygiene point of view. Under this exemption from veterinary inspection, the hunter must have shot the game in person and is personally responsible for its wholesomeness. "Local" is defined as the local authority area and the adjacent ones to that in which the game was killed. "Small quantities" are defined as < 300 deer carcasses a year and < 10,000 head of small game - not many stalkers can shoot, butcher and sell those amounts within approximately a 30 mile radius!

However, the primary producer, e.g. a sporting estate, is going to be more restricted. A primary producer will only be allowed to sell small quantities of "primary product", which is defined as unplucked/unskinned game, to local people or local retail establishments like butchers' shops. Under the new rules, unless they are approved as game dealers and adhere to a full HACCP plan, primary producers may not butcher and sell game meat (even in small quantities and locally).

Small-scale game dealers, and those estates which currently prepare and sell game meat and venison locally, are arguing that this ruling is too restrictive. In response to their complaints FSA may go back to EU to try to get authority to permit continued operation under Meat Hygiene Service (MHS) supervision, instead of requiring full veterinary presence and inspection of all product.

This move is already generating strong objections from those game dealers who are fully FSA-approved Game Handling Establishments (GHEs). There are only a few fully FSA-approved GHEs who are allowed to deal in and export wild game without any restrictions. Their plant and procedures have been inspected and approved by the Meat Hygiene Service and a vet is always present and inspects all carcasses. Having made this major investment in plant, vehicles and veterinary inspection, such dealers view any lower category of game dealing being allowed as unfair competition from "Fred in a Shed", who is able to undercut them due to his lower costs.

After 1 January 2006, ALL game supplied to ANY game dealer (as opposed to a retail butcher or the final consumer) must have been inspected by a "trained hunter". A numbered declaration must be attached to each deer carcass to this effect.

One exemption does exist which allows deer carcasses only still to be sold to a GHE by unqualified hunters, but each carcass will have to be accompanied by its head (less trophy), red offal i.e. "the pluck", and perhaps feet too, for the resident vet's inspection. It is likely that venison dealers will offer a lower price for such carcasses to cover their additional rubbish disposal costs.

Becoming a "Trained Hunter"

Becoming a "trained hunter" is not difficult for any competent deer stalker. Those who are already qualified, i.e. hold DSC Level 1, will only have to apply to DMQ for a modification to their original Level 1 certificate and certify that he/she has updated their knowledge about the recent legislation and updated handling procedures. This will best be done by studying the official Wild Game Handling Guide which is due to be published on 1 October. It is currently undergoing a formal consultation process. After 1 January 2006 all those attending DSC Level 1 courses will automatically be assessed as "trained hunters" under the approved Vocational Related Qualification (VRQ) system.

There are, of course, many people who are not currently qualified under DSC Level 1, including most of the professional gamekeepers in UK. A large number of these have already undertaken a one day course run by the National Gamekeepers Organisation to teach them the minimum meat handling skills required, which will allow them to sell venison and game after 1 January 2006.

Other Requirements

One problem for the average deer stalker who is not able to process all his carcasses "in-house" for consumption or local sale, and wants to sell them to a dealer, is that there are probably going to be very few GHEs. The capital and running costs involved are high. However, if local game dealers are forced to stop trading by the new laws which require veterinary inspection unless they comply with the small quantities, local and final consumer restrictions, it is likely that the larger plants will set up a network of local collection centres to absorb the local product which is not sold direct to final consumers by the hunters.

However the industry develops, it is clear that all deer stalkers should be making plans now to upgrade their larders and handling facilities to meet their own specific stalking requirements. Unless you are lucky enough to live close to a game dealer who is going to continue to trade after 1 January and you can sell your deer in skin the day it is shot, or perhaps the morning afterwards, you will need access to a proper deer larder with a chill. If you plan to skin, cut up and sell your carcasses, you will need somewhere more hygienic than your garage and kitchen table!

It is not possible to offer specific advice without knowing each persons individual circumstances and many stalkers have been daunted by seeing Forestry Commission larders costing well into six figures. However, with a bit of common sense, the enthusiastic collection of second-hand butcher shop furniture and equipment and some DIY skill or professional assistance, a perfectly adequate and hygienic larder can be constructed for a small scale stalker, or stalking syndicate, from quite unpromising buildings.